Dear Madam,
This letter relates to your interview with TV PAS, Mr Gilbert Almeida, on 29th of July 2011, and provides a follow up to comments that I posted on YouTube within days of its broadcast.
Firstly, I would like to state upfront that I am not an employee of Lynas Corporation; however I have been independently advising Lynas on the management of radiation protection issues for some time.
I provide this kind of technical advisory service to a large number of mining and mineral processing companies, national and international organisations and government departments around the world.
With all due respect, I find many of your technical comments in the abovementioned interview to be fundamentally flawed and inaccurate.
In addition, I consider several statements made by Mr Almeida, with which you appear to agree, as ill-informed and offensive.
I refer particularly to comments such as Australia exporting ‘radioactive death’ and that some people (presumably associated with Lynas) should be tried for ‘crimes against humanity’.
On radiation protection issues, I believe that as a Member of the Malaysian Parliament, you would not intentionally seek to mislead the people of Kuantan.
I therefore assume that you have been poorly and inadequately advised on the issues of rare earth processing, and I provide the following comments to specifically address the seven issues you highlight in the interview.
ISSUE 1: BEST PRACTICE GUIDELINES
The very first finding of the IAEA mission to review the Lynas Advanced Materials Plant is that “the review team was not able to identify any non-compliance with international radiation safety standards”.
These same standards are applicable to the treatment of radioactive ores – uranium, tin, titanium, phosphate, rare earths, zirconium, tantalum, niobium, etc.
The list of seventeen international (IAEA) documents that are applicable is provided on pages 8-9 of the IAEA Report.
Therefore, your comment that there are no benchmarks or best practice guidelines is incorrect and invalid.
ISSUE 2: ALLEGED USE OF THE STANDARDS OF THE PEOPLE’S REPUBLIC OF CHINA BY LYNAS
You state that “I have the evidence that Lynas is going to use China standards”. This allegation is quite extraordinary, as no document from Lynas or the IAEA has ever mentioned the use of standards other than Malaysian, Australian or International standards.
If you do have such evidence, it would be appreciated if you would make it public.
Until then, your statement cannot be taken seriously. It is clearly nothing more than an unproven and unjustified assertion.
ISSUE 3: THE DISTANCE BETWEEN RARE EARTH OPERATIONS AND RESIDENTIAL AREAS
The statement that “in Australia even to extract the rare earth elements it is mandatory for the operations to be located 35 km from residential areas” is a fabrication.
There is no law, regulation or even a guideline anywhere in Australia containing this requirement. Even the research nuclear reactor at Lucas Heights on the outskirts of
metropolitan Sydney, is located within two to three kilometres of residential areas.
Your have obviously been misled. Your statement is incorrect.
ISSUE 4: DISCUSSION AND EXPLANATION OF RADIOACTIVITY CONCENTRATIONS
It seems to me that your technical advisers are confusing numbers and different methods for calculating specific activity of materials.
There are two ways of calculating this value: the out-dated method of using ‘total’ activity, versus the current standard that uses concentration of a ‘parent’ radio-isotope.
This international standard has been in use since 1997-1998.
On this basis, if a material contains 400 parts per million of thorium – its specific activity is calculated as follows:
a) Outdated method – 400 x 4.09 (specific activity of Th-232) x 10 (number of radio nuclides in the thorium decay chain) = 16,360 Bq/kg, or 16.4 Bq/g
b) International standard (IAEA, AELB and Australia) – 400 x 4.09 = 1,630 Bq/kg, or 1.64 Bq/g.
The internationally accepted standard for the material to be considered for regulation is 1 Bq/g.
However, if the specific radioactivity of the material reaches or exceeds the value of 1 Bq/g, it does not necessarily mean that material is regulated and/or should be classified as ‘radioactive’.
There is a provision in the IAEA document RS-G-1.7 that the value may be up to 10 Bq/g and material may still be exempted from regulations when certain provisions are met.
Either someone misinformed you, or you have misunderstood the situation.
The Lynas Water Leach Product (WLP) at 6.1 Bq/g is, of course, classified as a ‘radioactive material’.
To the best of my knowledge, there are no documents where it was claimed that the Lynas residue is “under the Chinese standard” and therefore “can be disposed as any other waste”.
Your comment is incorrect. If, as you claim, Lynas is saying that the waste is not radioactive, then why did Lynas develop the radiation impact assessment for approval by AELB in 2007?
ISSUE 5: ABOUT THE DANGERS OF THE LYNAS RAW MATERIAL
It appears that you have again been misinformed - this time with regards to the processing of the Lynas ore. The ore is crushed in Western Australia, prior to being processed at the concentration plant, also located in Western Australia.
The material will then be transported in the form of a wet paste inside double-layered plastic bags, which will be sealed and placed into sea containers.
Therefore, your comment about the danger of dry dust particles is alarmist and misleading.
It also appears you may have misunderstood the danger of different types of radiation.
Contrary to your statement that “alpha is not as dangerous as gamma”, there is only one scientific opinion about ‘radiation weighting factors’ and that is that alpha radiation is actually twenty times more dangerous than gamma radiation.
ISSUE 6: CONCERNING THE POSSIBILITY OF URANIUM ESCAPING INTO WATER AND INTO THE SEA
I feel compelled to point out that your comments on the risk of uranium escaping into water are so outlandish that I would like, once again, to question the competence of your technical advisers.
It is clearly stated in the RIA that any water discharged will not exceed the standard specified by AELB of 1 Bq/L.
The most environmentally mobile, and thus potentially dangerous radioactive element is not uranium but radium, and by a considerable margin. Without detailed quoting:
*The limits set by AELB are within the range of concentrations allowed in the drinking water by both the Australian Government and the World Health Organisation (0.1 – 1.0 Bq/L);
*The limits are significantly below the natural concentration of radionuclides in drinking water in some areas of the world, as reported by United Nations Scientific Committee onthe Effects of Atomic Radiation (UNSCEAR) in its 2000 Report.
Effectively, you are claiming that if someone brings to Kuantan one tanker per year of the drinking water from certain locations in Finland (up to 150 Bq/L of uranium and 49 Bq/L of radium) or Switzerland (around 1 Bq/L of uranium and up to 1.5 Bq/L of radium) and pours it into the river near Kuantan, the fishing industry of all South-East Asia would be destroyed?
As I presented to the International Symposium on Naturally Occurring Radioactive Material in Spain in 2007, phosphate fertilisers commonly used in agriculture normally containbetween 50 and 500 Bq/kg of uranium, with the highest value being over 2000 Bq/kg. So, if we are to follow your logic, then a ship carrying phosphate fertiliser that loses its cargo near Kuantan would completely decimate the fishing industry due to extremely high radiation levels.
Your comment on the possible destruction of the fishing industry in South-East Asia is wide off the mark and I do not believe that you, as a Member of the Malaysian Parliament, would mislead people this way. I therefore suggest that and your technical advisers re-examine data to the utmost detail prior to repeating this kind of extreme and alarmist comment in public.
ISSUE 7 – ON RADIOACTIVE WASTE
I wish to draw to your attention that numerous industries within Malaysia, and around the world, generate radioactive waste. And if your comments are to be taken seriously, by shutting down industries that produce radioactive waste, a vast array of products, goods and services would no longer be available to society.
These include:
* Hybrid cars, energy-saving light bulbs, mobile phones, electricity-generating wind turbines, and almost all electronic and computer equipment
* Petrol and diesel fuel, all other mineral oils and natural gas
* Airplanes, space vehicles, white pigments, toothpaste
* Phosphate fertilisers for agriculture
* Ceramic tiles, porcelain
* Electricity generated by burning coal or geo-thermal sources
* products made from or with an addition of iron, copper, tin, aluminium, zinc, lead, tantalum, etc
* Clean drinking water produced from water treatment.
I am confident that you are “not against progress”; however, in following your own logic, the oil and gas industry in Malaysia should be shut down and people should be banned from using phosphate fertilisers, living in houses with ceramic tiles, driving cars, flying on airplanes, and using any kind of electronic equipment.
This is no exaggeration - simply an extension of your own logic.
As an expert in radiation protection, I would welcome the opportunity to provide you and your technical advisory team with any additional information and clarification you require.
I would also welcome an opportunity to discuss all radiation related issues in an open forum, without any pre-conditions. I am not an employee of Lynas Corporation and do not need to seek any approval to participate in such a discussion.
I am absolutely confident that a frank and open discussion about radiation-related issues surrounding not only the Lynas plant in Kuantan, but also in general terms, will be beneficial for everyone.
If you have any interest, please let me know and I will try to include a stopover in Kuala Lumpur into my schedule in the next few months.
Yours sincerely,
Kind regards
Nick Tsurikov
Calytrix Consulting Pty Ltd
Perth, Western Australia
4th August, 2011
